Harms of a Potential New FCC De-Competition Policy -- Reply comments to FCC Open Internet NPRM

The FCC's proposed Open Internet Regulations and/or the oft-rumored potential re-classification of broadband as a Title II telephone service effectively would create a new FCC "de-competition policy." (For the one-page PDF submitted to the FCC click here)

Ignoring the Federal fiscal reality that the FCC must rely on robust private investment for universal broadband;

Positing without evidence, that the FCC’s visible hand can outperform market’s invisible hand;

Deeming the lobbying contest for specially-granted regulatory prices, terms & conditions to be “competition,” but facilities-based, multi-technology competition for consumers’ business based on price, value, innovation, and differentiation – to not be competition; and

Over-reaching with big regulatory changes without authority, justification, or consensus.

Undermining the National Broadband Plan’s consensus with de-competition policy’s major strife.

Regressing backwards to a 19th century regulatory paradigm designed for a single technology monopoly (railroads), away from a 21st century competition paradigm for diverse technologies.

Ignoring the FCC’s well-known regulatory/legal failures from a decade ago and the consequent bubble speculation and crash they helped cause (CLEC & fiber bankruptcies, dotcom bubble) with no lessons-learned or analysis why new de-competition policy won’t result in déjà-vu.